I, Smt. Sukhamata aged about 54 years wife of Dayaram resident of Village – Kanrahiya, Mungar, Police Station – Gossainganj, District – Sultanpur, Religion – Hindu, Education – Literate, Occupation – Housewife, do hereby solemnly affirm and state on oath as under:- That the deponent is the mother/pariokar of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such he is fully conversant with the facts of the case and deposed as under. The ID Proof of the deponent is enclosed and his photograph is affixed to the affidavit. That the deponent further declares that the contents of the affidavit have been explained in Hindi by the counsel of the applicant to her 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 this is the first bail application of the applicant before this Hon'ble Court.  No any other bail application is pending before this  or rejected by this . That brief facts of the case are that a first information report was lodged against the applicant and two other persons on 16.08.2023 by the informant namely Smt. Sukhkha Devi wife of Vijay Kumar Vishwakarma resident of Village – Ramchandrapur, Police Station – Gossainganj, District – Sultanpur (hereinafter referred to as ‘informant’) bearing Case Crime No. 345 of 2023 under Sections 147, 323, 504, 506, 452, 34, 376, 511, 354B of IPC at Police Station – Gossainganj, District – Sultanpur regarding incident dated 09.08.2023.  The photocopy of the first information report dated 16.08.2023 is being annexed herewith as Annexure No. 01 to this affidavit. That according to the first information report the informant stated in her first information report that on 09.08.2023 around 10.00 hours, the daughter of the informant returning from the field at that one Prince brought her and committed rape with her. As per the first information report, another accused namely Chandradev alias Sidhdhu was making vedio and the applicant was present there. The informant further alleged the accused of the case crime threatened her daughter as such he did not told anything to anyone. That the alleged incident which was occurred on 09.08.2023 around 10.00 hours but the first information report was lodged on 16.08.2023 after about 7 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 and her family lodged aforesaid first information after legal advice. That the statement of the informant under Section 161 Cr.P.C. has been recorded by the concerned police, in which she slightly changed her statement and tried to develop her prosecution story. The typed copy of the statement of the informant under Section 161 Cr.P.C. is being annexed herewith as Annexure No. 02 to this affidavit. That the victim was medically examined on 16.08.2023 at District Women Hospital, Sultanpur and her medical report does not corroborate the prosecution story and nothing has been found regarding the commission of rape with her. The photo/ typed copy of the medical report dated 04.08.2022 of the victim is being annexed as Annexure No. 03 to this affidavit. That the statement of the daughter of the informant under Section 161 Cr.P.C. has been recorded by the concerned police, in which she almost repeated the version of the first information report and stated against the applicant that he was present at the time of the alleged incident. The typed copy of the statement of the daughter of the informant under Section 161 Cr.P.C. is being annexed herewith as Annexure No. 04 to this affidavit. That the statement of the victim under Section 164 Cr.P.C. was recorded before the concerned court on 19.08.2023, in which she changed her statement of the 161 of Cr.P.C. as well as the version of the first information report and stated that the applicant has also committed rape with her. The typed copy of the statement of the victim under Section 164 of Cr.P.C. dated 19.08.2023 is being annexed herewith as Annexure No. 05 to this affidavit. That the statement of the victim given under Sections 161 & 164 is not trustworthy as both statements have several contradictions, which have been clearly shown the same. That according to the prosecution story, it clearly reveals that story of the prosecution is based on only false, incorrect facts and grounds and concerned police avoiding the truth of the case and there is no evidence against the applicant. That the real fact of the case is that the applicant has no concern with the alleged incident in any manner, the applicant has been falsely implicated by the informant due to extraneous reasons. That the applicant is the friend of another accused Chandradev Vishawkarma alias Sidhdhu and the third accused Prince is the common friend of the applicant and another. That the informant and her family have enmity with the family of another accused Chandradev Vishawkarma alias Sidhdhu, due to which a false case has been lodged against the applicant and his friends due to personal revenge and party-bandi. That against the applicant, no role was assigned in the first information report, in the statements of the informant & her daughter recorded under Section 161 of Cr.P.C. but suddenly at the time recording the statement under Section 164 of Cr.P.C., the entire prosecution story has been changed by the informant & her daughter. That the whole story was cooked by the informant and her family members against the applicant and explained by the concerned police after knowing everything, while the applicant has no concerns with the said incident. That without proper investigation of the case, the investigating officer submitted charge sheet under Sections          against the applicant. The photocopy of the charge sheet dated submitted by the concerned police is being annexed herewith as Annexure No. 06 to this affidavit. That except the present case, the applicant has no criminal history. That there is no any evidence against the applicant to connect him with the aforesaid case crime. That since the applicant has not committed any offense as alleged but he has been falsely implicated in the case by the informant and their family members with malafide intentions. That the case of the informant is to be proved beyond reasonable doubt and cannot take support from the weakness of the case of defense. In case the evidence is read in totality and the story projected by the informant is found to be improbable, the prosecution case becomes liable to be rejected. If evidence of the informant is read and considered in the totality of circumstances along with other evidence on record, in which offense is alleged to have been committed, his deposition does not inspire confidence. That where the evidence of the informant is found suffering from serious infirmities and inconsistencies with other material, then no reliance can be placed upon her evidence. The onus is always on the informant to prove and the informant is entitled to the benefit of reasonable doubt. That in the present case there is sufficient evidence on record to show that the applicant did not have the motive to commit the offense. That since the applicant has not committed any offense as alleged but he has been falsely implicated in the case by the informant and their family members with malafide intentions. That the applicant moved bail application bearing No. 2938 of 2023 before Sessions Judge, Sultanpur, and his bail application was rejected by the court concerned on 07.10.2023 without considering the grounds. The free certified copy of the order dated 07.10.2023 passed by the court concerned is being annexed herewith as Annexure No. 07 to this affidavit. That the applicant is in jail since   .2023 without committing any offense as alleged against the applicant. That the applicant has no criminal history except the aforesaid false case and is not likely to hope in the future to commit any offense. That there is no chance of the applicant absconding or tempering with the prosecution witnesses. That the applicant is ready to furnish the security and bond and also undertakes that he will never misuse the liberty of bail. That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail in connection with Case Crime No. 345 of 2023 under Sections 376-D, 506, 34 of IPC and 67 of the Information of Technology Act registered at Police Station – Gossainganj, District – Sultanpur, in the interest of justice.


I, Subham Singh aged about 29 years son of Shri Awadhesh Kumar Singh resident of Village - Sajampur, Post - Harpur, Jagdishpur, Police Station - Akhand Nagar, District - Sultanpur, Religion – Hindu, Education – Literate, Occupation – __________, do hereby solemnly affirm and state on oath as under:- That the deponent is the son/pairokar of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and the content of the application & affidavit have been explained by the counsel of the applicant in Hindi to her and as such she is fully conversant with the facts of the case and deposed as under. The ID Proof of the deponent is enclosed and her photo affidavit issued by the Awadh Bar Association, Lucknow is affixed to the affidavit. That this is the first bail of the applicant filed before this Hon’ble Court and no other bail application on the same cause of action is filed or pending in any court of law. 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 on 30.06.2008 at about 23.00 Hours, the informant Shri P. P. Singh, Station House Officer, Police Station – Kadipur, District – Sultanpur (hereinafter referred to as ‘informant’) lodged a first information report against 04 persons including the applicant as Case Crime No. 794 of 2008 under Section 3(1) of U.P. Gangster and Anti-Social Activities (Prevention) Act, 1986 (hereinafter referred to as ‘Gangster Act’) in Police Station – Kadipur, District – Sultanpur. The photo and typed copy of the first information report dated 30.06.2008 is being annexed herewith as Annexure No. 1 to this affidavit. That brief fact of the alleged prosecution story is that the alleged accused as mentioned in the first information report are committing the crime, regularly as they are habitual, for their economic benefit, and due to their terror, no one can dare to speak against them. The photocopy of the gang chart is being annexed herewith as Annexure No. 2 to this affidavit. That for proper adjudication of the case it is submitted that the applicant is totally innocent and does not commit any offense as alleged in the first information report by the informant. That the informant in order to show his good and hard work, falsely implicated the applicant in four cases, including the present case crime, in which the present bail is being filed by this applicant, and thereafter finally lodged the said first information report dated 30.06.2008 under 3(1) of Gangster Act: Case Crime No.  594 of 2008 under Sections 420, 467, 468, 471, 120-B, 506 of IPC registered at Police Station – Kadipur, District – Sultanpur, in which the applicant has been granted bail by the court below on 18.09.2023. Case Crime No. 783 of 2008 under Sections 420, 467, 468, 471 of IPC registered at Police Station – Kadipur, District - Sultanpur, in which the applicant has been granted bail by the court below on 22.09.2023. Case Crime No. 784 of 2008 under Section 387 of IPC registered at Police Station - Kadipur, District - Sultanpur, in which the applicant has been granted bail by the court below on 22.09.2023. The photocopies of the orders dated 18.09.2023 & 22.09.2023 passed by the court concerned are being annexed herewith collectively as Annexure No. 3 to this affidavit. That it is relevant to mention here that the applicant is a common man of society. He is neither a member of the alleged gang as alleged in the first information report nor involves any crime as alleged against him in the gang chart by the informant. He further does not do any offense for his economic and physical benefit due to which the local area people are under threat as such allegations against the applicant are false and fabricated. That the applicant in jail since ___.___._______ without committing any offense as alleged by the informant in relation the impugned case crime. That the applicant has no concern with any gang in any manner as alleged by the informant and also the prosecution story is totally against the circumstances and facts and the same is not reliable in manner. That 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 the Gangster has been imposed by the concerned police only on the basis of only case, which is already lodged on the false and incorrect facts against the applicant. That the applicant had moved his bail application No. 2696 of 2023 before the Additional District & Session Judge/ FTC Second/Special Judge Gangster Act, Sultanpur and the same was rejected on 16.09.2023 without considering the version of the applicant. The certified copy of the bail rejection order dated 16.09.2023 is annexed herewith as Annexure No. 4 to this affidavit. That the applicant will not misuse the liberty of bail if so granted by this Court. That the applicant has no motive to commit the alleged crime and a false motive which given in the case, is cooked and fabricated by the concerned police. 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, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail in connection with Case Crime No. 794 of 2008 under Sections 3(1) of U.P. Gangster and Anti-Social Activities (Prevention) Act, 1986 registered at Police Station – Kadipur, District – Sultanpur, during the pendency of his trial, during the pendency of his trial, in the interest of justice.


I, Virendr Kumar aged about 47 years son of Shri Ram Das resident of Village – Rajapur, Police Station – Gosainganj, District - Sultanpur, Education – Literate, Occupation – _________________, do hereby solemnly affirm and state on oath as under:- That the deponent is the father/pairokar of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such he is fully conversant with the facts of the case and deposed as under. The ID Proof of the deponent is enclosed and his photo affidavit issued by the Awadh Bar Association, Lucknow is affixed to the affidavit. That this is the first bail of the applicant filed before this Hon’ble Court and no other bail application on the same cause of action is filed or pending in any court of law. 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 on 27.04.2024 at about 22.23 Hours, the informant Shri Dhiraj Kumar, Inspector, Police Station – Gosainganj, District – Sultanpur lodged a first information report against 2 persons including the applicant at Case Crime No. 171 of 2024 under Section 2, 3(1) U.P. Gangster and Anti-Social Activities (Prevention) Act, 1986 (hereinafter referred to ‘Gangster Act’) in Police Station – Gosainganj, District – Sultanpur. The certified and typed copy of the first information report dated 27.04.2024 is being annexed herewith as Annexure No. 1 to this affidavit. That brief fact of the alleged prosecution story is that the alleged accused as mentioned in the first information report are committing the crime, regularly as they are habitual, for their economic benefit, and due to their terror, no one can dare to speak against them. That prior to lodging the aforesaid case crime against the applicant and another, the gang chart was approved by the District Magistrate, Sultanpur on 09.04.2024. The photocopy of the gang chart dated 09.04.2024 is being annexed herewith as Annexure No. 2 to this affidavit. That for proper adjudication of the case it is submitted that the applicant is totally innocent and does not commit any offense as alleged in the first information report by the informant. That the informant in order to show his good and hard work, falsely implicated the applicant in a case and thereafter finally lodged the said first information report dated 27.04.2024 under Section 2, 3(1) Gangster Act: Case Crime No.  452 of 2023 under Sections 307 of IPC, 33 5A, 8 of Prevention of Cow Slaughter Act and 11 of Prevention of Cruelty to Animal Act registered at  Police Station – Gosainganj, District – Sultanpur, in which, the applicant has enlarged on bail by the Additional District and Sessions Judge/ F.T.C. Second, Sultanpur vide its order dated 01.12.2023. The photocopy of the order dated 01.12.2023 passed by Additional District and Sessions Judge/ F.T.C. Second, Sultanpur is being annexed herewith as Annexure No. 3 to this affidavit. That it is relevant to mention here that the applicant is a common man of society. He is neither a member of the alleged gang as alleged in the first information report nor involves any crime as alleged against him in the gang chart by the informant. He further does not any offense for his economic and physical benefit due to which the local area people are under threat as such allegations against the applicant are false and fabricated. That the applicant in jail since 26.04.2024 without committing any offense as alleged by the informant in relation the impugned case crime. That the applicant has no concern with any gang in any manner as alleged by the informant and also the prosecution story is totally against the circumstances and facts and is not reliable in manner. That 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 the applicant had moved his bail application bearing No. 1210 of 2024 before the Bail was rejected by Additional Session and Judge/ F.T.C. First/ Special Judge Gangster Act, Sultanpur, and the same was rejected on 02.05.2024, in a very mechanical manner without considering the fact of the case. The certified copy of the bail rejection order dated 02.05.2024 is annexed herewith as Annexure No. 4 to this affidavit. That the applicant will not misuse the liberty of bail if so granted by this Court. That the applicant has no motive to commit the alleged crime and a false motive which given in the case, is cooked and fabricated by the concerned police. 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, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail in connection with Case Crime No. 171 of 2024 under Sections 2, 3(1) U.P. Gangster and Anti-Social Activities (Prevention) Act, 1986 registered at Police Station – Gosainganj, District – Sultanpur, in the interest of justice.


I, Ajay Kumar Singh aged about 52  years son of Shri Ram Lakhan Singh resident of Village - Basantpur, Tiwaripur, Post - Chandaur, Police Station - Kurwvar, District - Sultanpur, Education – Literate, Occupation – _________________, do hereby solemnly affirm and state on oath as under:- That the deponent is the brother/pairokar of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such he is fully conversant with the facts of the case and deposed as under. The ID Proof of the deponent is enclosed and his photo affidavit issued by the Awadh Bar Association, Lucknow is affixed to the affidavit. That this is the first bail of the applicant filed before this Hon’ble Court and no other bail application on the same cause of action is filed or pending in any court of law. 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 on 26.03.2024 at about 18.50 Hours, the informant namely Shri Rakesh Singh, Station House Officer, Police Station – Jagdishpur, District – Amethi lodged a first information report against 5 persons including the applicant at Case Crime No. 109 of 2024 under Section 2, 3(1) U.P. Gangster and Anti-Social Activities (Prevention) Act, 1986 (hereinafter referred to ‘Gangster Act’) in Police Station – Jagdishpur, District – Amethi. The certified and typed copy of the first information report dated 26.03.2024 is being annexed herewith as Annexure No. 1 to this affidavit. That brief fact of the alleged prosecution story is that the alleged accused as mentioned in the first information report are committing the crime, regularly as they are habitual, for their economic benefit, and due to their terror, no one can dare to speak against them. That prior to lodging the aforesaid case crime against the applicant and another, the gang chart was approved by the District Magistrate, Sultanpur. The photocopy of the gang chart is being annexed herewith as Annexure No. 2 to this affidavit. That for proper adjudication of the case it is submitted that the applicant is totally innocent and does not commit any offense as alleged in the first information report by the informant. That the informant in order to show his good and hard work, falsely implicated the applicant in a case and thereafter finally lodged the said first information report dated 26.03.2024 under Section 2, 3(1) Gangster Act: Case Crime No.  255 of 2023 under Sections 379, 411, 413 of I.P.C. and 10 Goonda Act registered at  Police Station – Jagdishpur, District – Amethi, in which, the applicant has enlarged on bail by the Additional District and Sessions Judge, Room No. 3, Sultanpur vide its order dated 18.08.2023. The photocopy of the order dated 18.08.2023 passed by Additional District and Sessions Judge, Room No. 3, Sultanpur is being annexed herewith as Annexure No. 3 to this affidavit. That it is relevant to mention here that the applicant is a common man of society. He is neither a member of the alleged gang as alleged in the first information report nor involves any crime as alleged against him in the gang chart by the informant. He further does not any offense for his economic and physical benefit due to which the local area people are under threat as such allegations against the applicant are false and fabricated. That the applicant in jail since              without committing any offense as alleged by the informant in relation the impugned case crime. That the applicant has no concern with any gang in any manner as alleged by the informant and also the prosecution story is totally against the circumstances and facts and is not reliable in manner. That 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 the applicant had moved his bail application bearing No. 2723 of 2024 before the Bail was rejected by Additional Session and Judge/ Special Judge Gangster Act, Room No. 1, Sultanpur, and the same was rejected on 05.10.2024, in a very mechanical manner without considering the fact of the case. The free copy of the bail rejection order dated 05.10.2024 passed by the learned court below is annexed herewith as Annexure No. 4 to this affidavit. That the applicant will not misuse the liberty of bail if so granted by this Court. That the applicant has no motive to commit the alleged crime and a false motive which given in the case, is cooked and fabricated by the concerned police. 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, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail in connection with Case Crime No. 109 of 2024 under Sections 2, 3(1) U.P. Gangster and Anti-Social Activities (Prevention) Act, 1986 registered at Police Station – Jagdishpur, District – Amethi, in the interest of justice.


I, Sonu Sonkar aged about 28 years son of Shri Hridayram Sonkar resident of Sisauda, Mahamudpur, Semari, Police Station - Jaisinghpur, District - Sultanpur, Education – Literate, Occupation – Vegetable seller, do hereby solemnly affirm and state on oath as under:- That the deponent is the brother/pairokar of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such he is fully conversant with the facts of the case and deposed as under. The ID Proof of the deponent is enclosed and his photograph is affixed to the affidavit. 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 this is the first bail application of the applicant before this Hon'ble Court.  No any other bail application is pending before this  or rejected by this . That brief fact of the case is that; on 23.08.2023 at 17.09 hours the first information report lodged by the informant Satish Gupta against the unknown person bearing Case Crime No. 493 of 2023 under Sections 379 of I.P.C. and 197 of the Motor Vehicle Act, 1988 registered at Police Station – Akbarpur, District – Ambedkar Nagar.  The certified/ photocopy of the first information report dated 23.08.2023 is being annexed as Annexure No. 01 to this affidavit. That the brief of the first information report, in a nutshell, is that on 25.07.2023 around 05.30 P.M., the motorcycle of the informant was stolen by an unknown person and when it was found then the informant lodged the first information report. That on 28.08.2023, the statement of the informant was recorded by the concerned police under Section 161 of Cr.P.C., in which he repeated his first information report version. The typed copy of the statement of the informant dated 28.08.2023 is being annexed as Annexure No. 02 to this affidavit. That later on, on the basis of the false and incorrect information, the applicant was arrested along with two other accused and also recovered the 8 motorcycles, one mobile phone, and a first information report bearing Case Crime No. 196 of 2023 under Sections 41, 411, 413, 420, 467, 468, 471 of I.P.C., registered at Police Station – Aliganj, District – Ambedkar Nagar lodged against the applicant and others on 02.09.2023. That the applicant is innocent and has no concerns with the alleged recovery of the vehicles and he has been falsely implicated in the case crime for extraneous reasons by the concerned police to show his good work in the department. That so far as the recovery of the mobile phone, it was owned by the applicant and there is no any recovery was made from the possession of the applicant. That after the arrest of the applicant, his name was revealed in Case Crime No. 493 of 2023 and under the life threat, the confessional statement of the applicant was recorded/written by the investigating officer of the case crime on 09.09.2023 as per his wish, while the applicant has no concern with the alleged incident. That the real fact of the case is that the applicant was working as a helper with the co-accused Puneet Yadav, on the truck, which was driven by Puneet Yadav for a long back. That the father of co-accused Puneet Yadav lodged the first information report against the informant of the police, bearing Case Crime No 186 of 2022 under Sections 147, 452, 323, 504, 506 of I.P.C. at Police Station - Bewana, District - Ambedkar Nagar as such the co-accused has been arrested from his house along with the applicant when he was visited at the house of the co-accused. That being the friend of the co-accused, the applicant has been falsely named in the first information report whereas the applicant has no concern with the alleged recovery in any manner. The concerned police blindly believe the version of the informant without any substantial evidence. That on perusal of the first information report and the entire records, no case is made out against the applicant under Sections 379, 411 of I.P.C.. That the first information report has been lodged against the applicant on the basis of the false, fabricated, and concocted story without any rhyme, reason, or basis whereas the applicant has not committed any offense. That after lodging the aforesaid case crime No. 196 of 2023, the concerned police also named in the first information reports, which are as under:- Case Crime No. 408 of 2023 under Sections 379 of I.P.C. and 197 of M. V. Act, 1988 registered at Police Station - Akabarpur, District - Ambedkar Nagar. Case Crime No. 186 of 2022 lodged under Sections 506, 504, 323, 452, 147 at Police Station - Bewana, District - Ambedkar Nagar. Case Crime No. 66 of 2023 lodged under Sections 379 of I.P.C. at Police Station - Vibhuti Khand, District - Lucknow. Case Crime No. 196 of 2023 under Sections 41, 411, 413, 420, 467, 468, 471 of I.P.C., registered at Police Station – Aliganj, District – Ambedkar Nagar, in which the applicant has been granted bail by this Hon'ble High Court vide order dated 11.12.2023. The applicant has not named in the serial No. (i) to (iii) of the aforesaid listed case crimes. The photocopies of the first information report and order dated 11.12.2023 passed by this Hon'ble High Court are being annexed herewith as Annexure No. 03 to this affidavit. That apart from above mentioned cases, as per best the best knowledge of the applicant, no other criminal history. That the informant has lodged the first information report on the false and incorrect facts and due to languishing in jail, the applicant as well as his entire family suffers from hardship without any fault on his part. That there were no any independent witnesses produced by the informant moreover if any witnesses is produced by the informant and victim they are interested witnesses. That it is also relevant to mention here that there is no case has been made out against the applicant as alleged against him and the applicant has never committed any offence as alleged. That the whole story was cooked and explained by the concerned police after knowing everything. That the informant is not the ocular witness and prosecution story as narrated therein is highly improbable, improper and unnatural and unbelievable for a prudent man. That the co-accused filed a bail application bearing Crl. Misc. Case No. 14412 (B) of 2023 (Puneet Yadav Vs State of U.P.) before this Hon'ble High Court, which has been allowed by this Hon'ble High Court vide its order dated 07.12.2023. The photocopy of the order dated 07.12.2023 passed by this Hon'ble High Court is being annexed herewith as Annexure No. 04 to this affidavit. That the case of the applicant is similar to co-accused as the applicant has to be granted the parity of the co-accused as nothing has been done by the applicant as alleged against the applicant. That the applicant moved bail application bearing No. 37 of 2024 before Additional Sessions Judge, (POCSO-First), Ambedkar Nagar, and his bail application was rejected by the court concerned on 05.02.2024. The certified copy of the order dated 05.02.2024 passed by the court concerned is being annexed as Annexure No. 05 to this affidavit. That the applicant in jail since 02.09.2023 without committing any offense as alleged against the applicant. That the applicant has no criminal history except the aforesaid false cases and is not likely to hope in the future to commit any offence. That there is no chance of the applicant absconding or tempering with the prosecution witnesses. That the applicant is ready to furnish the security and bond and also undertakes that he will never misuse the liberty of bail. That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail in connection with Case Crime No. 493 of 2023 under Sections 379, 411 of I.P.C., registered at Police Station – Akbarpur, District – Ambedkar Nagar, during the pendency of the case.


I, Sonu Sonkar aged about 28 years son of Shri Hridayram Sonkar resident of Sisauda, Mahamudpur, Semari, Police Station - Jaisinghpur, District - Sultanpur, Religion – Hindu, Education – Literate, Occupation – Vegetable seller, do hereby solemnly affirm and state on oath as under:- That the deponent is the brother/pairokar of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such he is fully conversant with the facts of the case and deposed as under. The ID Proof of the deponent is enclosed and his photograph is affixed to the affidavit. 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 this is the first bail application of the applicant before this Hon'ble Court.  No any other bail application is pending before this  or rejected by this . That brief fact of the case is that; on 02.09.2023 at 23.15 hours the first information report lodged by the informant Ram Ugrah Kushwaha against the applicant and 5 others bearing Case Crime No. 196 of 2023 under Sections 41, 411, 413, 420, 467, 468, 471 of I.P.C. registered at Police Station – Aliganj, District – Ambedkar Nagar.  The certified/ photocopy of the first information report dated 02.09.2023 is being annexed as Annexure No. 01 to this application. That the brief of the first information report, in a nutshell, is that the informant on the basis of the information arrested the three accused along with the applicant and also recovered the 8 motorcycles, and one mobile phone and lodged the first information report. That the applicant is innocent and has no concerns with the alleged recovery of the vehicles and he has been falsely implicated in the case crime for extraneous reasons by the concerned police to show his good work in the department. That so far as the recovery of the mobile phone, it was owned by the applicant and there is no any recovery was made from the possession of the applicant. That after the arrest of the applicant, under the life threat, the confessional statement was recorded by the concerned as per his with, while the applicant has no concern with the alleged incident. That there were no public or independent witnesses produced by the police in the instant matter, as such whole prosecution story is false and based on a concocted story. That the applicant was working as a helper with the co-accused Puneet Yadav, on the truck, which was driven by Puneet Yadav for a long back. That the father of co-accused Puneet Yadav lodged the first information report against the informant of the police bearing Case Crime No 186 of 2022 under Sections 147, 452, 323, 504, 506 of I.P.C. at Police Station - Bewana, District - Ambedkar Nagar as such the co-accused has been arrested from his house along with the applicant when he was visited at the house of the co-accused. That being the friend of the co-accused, the applicant has been falsely named in the first information report whereas the applicant has no concern with the alleged recovery in any manner. The concerned police blindly believe the version of the informant without any substantial evidence. That on perusal of the first information report and the entire records, no case is made out against the applicant under Sections 41, 411, 413, 420, 467, 468, 471 of I.P.C.. That the first information report has been lodged against the applicant on the basis of the false, fabricated, and concocted story without any rhyme, reason, or basis whereas the applicant has not committed any offense. That after lodging the aforesaid case crime, the concerned police also named in the first information report dated 18.07.2023 as Case Crime 408 of 2023 under Sections 379 of I.P.C. and 197 of M. V. Act and in the first information report dated 23.08.2023 as Case Crime No. 493 of 2023 under Sections 379 of I.P.C. and 197 of M. V. Act while the applicant was not named in both first information reports. The photocopies of the first information report dated 18.07.2023 and 23.08.2023 are being annexed herewith as Annexure No. 02 to this application. That the informant has lodged the first information report on the false and incorrect facts and due to languishing in jail, the applicant as well as his entire family suffers from hardship without any fault on his part. That there was no any independent witnesses produced by the informant moreover if any witness is produced by the informant and victim they are interested witnesses. That it is also relevant to mention here that there is no case is made out against the applicant as alleged against him and applicant has never committed any offence as alleged. That the whole story was cooked and explained by the concerned police after knowing everything. That the informant is not the ocular witness and prosecution story as narrated therein is highly improbable, improper and unnatural and unbelievable for a prudent man. That the co-accused filed a bail application bearing Crl. Misc. Case No. 13414 (B) of 2023 (Puneet Yadav Vs State of U.P.) before this Hon'ble High Court, which has been allowed by this Hon'ble High Court vide its order dated 09.11.2023. The photocopy of the order dated 09.11.2023 passed by this Hon'ble High Court is being annexed herewith as Annexure No. 03 to this application. That the case of the applicant is similar to co-accused as the applicant has to be granted the parity of the co-accused as nothing has been done by the applicant as alleged against the applicant. That the applicant moved bail application bearing No. 1006 of 2023 before Sessions Judge, Ambedkar Nagar, and his bail application was rejected by the court concerned on 21.11.2023. The free certified copy of the order dated 21.11.2023 passed by the court concerned is being annexed as Annexure No. 04 to this application. That the applicant in jail since 02.09.2023 without committing any offense as alleged against the applicant. That the applicant has no criminal history except the aforesaid false cases and is not likely to hope in the future to commit any offence. That there is no chance of the applicant absconding or tempering with the prosecution witnesses. That the applicant is ready to furnish the security and bond and also undertakes that he will never misuse the liberty of bail. That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail in connection with Case Crime No. 196 of 2023 under Sections 41, 411, 413, 420, 467, 468, 471 of I.P.C., registered at Police Station – Aliganj, District – Ambedkar Nagar, during the pendency of the case.


I, Sonu Sonkar aged about 28 years son of Shri Hridayram Sonkar resident of Sisauda, Mahamudpur, Semari, Police Station - Jaisinghpur, District - Sultanpur, Education – Literate, Occupation – Vegetable seller, do hereby solemnly affirm and state on oath as under:- That the deponent is the brother/pairokar of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such he is fully conversant with the facts of the case and deposed as under. That this is the first bail application of the applicant before this Hon'ble Court.  No any other bail application is pending before this  or rejected by this . That brief fact of the case is that; the first information report lodged by the informant Shri Suresh Kumar Yadav against the unknown person bearing Case Crime No. 66 of 2023 lodged under Sections 379 of I.P.C. at Police Station - Vibhuti Khand, District - Lucknow.  The certified/ photocopy of the first information report dated 09.02.2023 is being annexed as Annexure No. 01 to this affidavit. That the brief of the first information report, in a nutshell, is that., the motorcycle of the informant was stolen by an unknown person. That later on, on the basis of the false and incorrect information, the applicant was arrested along with two other accused and also recovered the 8 motorcycles, one mobile phone, and a first information report bearing Case Crime No. 196 of 2023 under Sections 41, 411, 413, 420, 467, 468, 471 of I.P.C., registered at Police Station – Aliganj, District – Ambedkar Nagar lodged against the applicant and others on 02.09.2023. That the applicant is innocent and has no concerns with the alleged recovery of the vehicles and he has been falsely implicated in the case crime for extraneous reasons by the concerned police to show his good work in the department. That so far as the recovery of the mobile phone, it was owned by the applicant and there is no any recovery was made from the possession of the applicant. That after the arrest of the applicant, his name was revealed in Case Crime No. 493 of 2023 and under the life threat, the confessional statement of the applicant was recorded/written by the investigating officer of the case crime on 09.09.2023 as per his wish, while the applicant has no concern with the alleged incident. That the real fact of the case is that the applicant was working as a helper with the co-accused Puneet Yadav, on the truck, which was driven by Puneet Yadav for a long back. That the father of co-accused Puneet Yadav lodged the first information report against the informant of the police, bearing Case Crime No 186 of 2022 under Sections 147, 452, 323, 504, 506 of I.P.C. at Police Station - Bewana, District - Ambedkar Nagar as such the co-accused has been arrested from his house along with the applicant when he was visited at the house of the co-accused. That being the friend of the co-accused, the applicant has been falsely named in the first information report whereas the applicant has no concern with the alleged recovery in any manner. The concerned police blindly believe the version of the informant without any substantial evidence. That on perusal of the first information report and the entire records, no case is made out against the applicant under Sections 379 of I.P.C.. That after lodging the aforesaid case crime No. 196 of 2023, the concerned police also named in the first information reports, which are as under:- Case Crime No. 408 of 2023 under Sections 379 of I.P.C. and 197 of M. V. Act, 1988 registered at Police Station - Akabarpur, District - Ambedkar Nagar. Case Crime No. 186 of 2022 lodged under Sections 506, 504, 323, 452, 147 at Police Station - Bewana, District - Ambedkar Nagar. Case Crime No. 493 of 2023 under Sections 379 of I.P.C. and 197 of the Motor Vehicle Act, 1988 registered at Police Station – Akbarpur, District – Ambedkar Nagar. Case Crime No. 196 of 2023 under Sections 41, 411, 413, 420, 467, 468, 471 of I.P.C., registered at Police Station – Aliganj, District – Ambedkar Nagar, in which the applicant has been granted bail by this Hon'ble High Court vide order dated 11.12.2023. The applicant has not named in the serial No. (i) to (iii) of the aforesaid listed case crimes. That it is also relevant to mention here that there is no case has been made out against the applicant as alleged against him and the applicant has never committed any offence as alleged. That the whole story was cooked and explained by the concerned police after knowing everything. That the applicant moved bail application concerned Magistrate, which has been rejected on   .2024. The certified copy of the order dated   .2024 passed by the court concerned is being annexed as Annexure No. 05 to this affidavit. That the applicant in jail since 02.09.2023 without committing any offense as alleged against the applicant. That the applicant has no criminal history except the aforesaid false cases and is not likely to hope in the future to commit any offence. That there is no chance of the applicant absconding or tempering with the prosecution witnesses. That the applicant is ready to furnish the security and bond and also undertakes that he will never misuse the liberty of bail. That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail, in the interest of justice.


I, Shyam Bahadur Singh aged about 56 years son of Shri Ram Kewal Singh resident of Village - Madhuban, Post - Bansgaon, Police Station - Gosainganj, District – Sultanpur, Religion – Hindu, Education – Literate, Occupation – Agriculture, do hereby solemnly affirm and state on oath as under:- That the deponent is the uncle/pairokar of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such he is fully conversant with the facts of the case and deposed as under. The photo verification slip issued by the Awadh Bar Association, Lucknow of the deponent is affixed on the affidavit and his ID proof is enclosed with the affidavit. That the deponent further declared that the contents of the bail application have been explained by the counsel of the applicant in Hindi and as such he is fully conversant with the facts of the case deposed as under. That this is the first bail application before this Hon'ble Court. No any other bail application is pending before this Hon'ble Court or rejected by this Hon'ble Court. That brief fact of the case is that a first information report was lodged against one known and some unknown persons on 14.10.2023 at 10.33 hours by Smt. Phoolkali wife of Suresh Nishad resident of Village - Madhuban, Post - Bansgaon, Police Station - Gosainganj, District – Sultanpur (hereinafter referred to as ‘informant’) under Sections 302 of I.P.C. at Police Station – Gosainganj, District – Sultanpur regarding the murder of his father-in-law only on basis of wrong, false and presumption. The certified typed copy of the first information report dated 14.10.2023 is being annexed as Annexure No. 01 to this affidavit. That according to the first information report lodged on 14.10.2023, the named accused along with unknown persons in the evening of 13.10.2023 went to the house of the informant and abused and given a life threat for the murder of the father-in-law of the informant. The informant further stated that the named accused and others had murdered her father-in-law. That the inquest report of the deceased body was prepared by the concerned police on 14.10.2023 in the presence of several villagers. That the body of the deceased was brought to the P. M. House, Sultanpur for conducting a post-mortem on 14.10.2023, where the post-mortem was conducted and the cause of the death was ascertained as ‘Hamarrage and Shock, due to ante-mortem injuries.”. The photo/ typed copy of the post-mortem report dated 14.10.2023 is being annexed as Annexure No. 03 to this affidavit. That the version of the first information report is totally false and baseless and the same depends upon the concocted story as such nothing happened as alleged by the informant in her first informant report. Here it is relevant to mention that the applicant was not named in the first information report. That the investigating officer recorded the statement of the informant under Section 161 of Cr.P.C. on 14.10.2023 in which the informant almost repeated her first information report. The typed copy of the statement of the informant dated 14.10.2023 is being annexed as Annexure No. 03 to this affidavit. That the further statement of the informant was recorded by the investigating officer under Section 161 of Cr.P.C. on 15.10.2023, in which she changed her statement and named the applicant only on the basis of resumption & her imagination. The typed copy of the further statement of the informant dated 15.10.2023 is being annexed as Annexure No. 04 to this affidavit. That on the applicant was arrested by the concerned police on 20.10.2023 from his home but for showing his good work, his arrest was shown in a forged and fabricated arresting memo dated 20.10.2023. Another accused was also arrested by the concerned police on the same day. That thereafter, the confessional statements of the co-accused and applicant have been written/ prepared by the Investigating Officer on 20.10.2023 as per his wish and tried their best to collaborate with the alleged incident and witnesses under section 161 Cr.P.C. only to prove the offense against the applicant whereas the applicant has not committed any offense. The typed copy of the confessional statement of the applicant and co-accused dated 20.10.2023 is being annexed as Annexure No. 05 to this affidavit. That the confessional statements of the other accused were recorded by the concerned police on 20.10.2023 under the life threat, in which he stated that the murder of the deceased was planned by all the accused as the named accused fought with the deceased on 13.10.2023. However, the applicant was reached at the time of the commission of the alleged offense. That the confessional statements of the arrested co-accused and applicant were recorded by the concerned police on 20.10.2023 under the life threat, in which the applicant said everything as narrated by the concerned police. That it is most humbly submitted that the applicant is innocent and he has falsely been implicated by the informant in the instant case and there is no evidentiary value in the eye of the law relating to the confessional statements given by the arrested accused. That on the basis of such a story, which was narrated by the investigating officer himself, without proper investigation of the case crime, submitted the charge sheet against the applicant and another accused on 13.11.2023. That the real story is that the applicant has no concern with the alleged offense and he has been falsely implicated by the informant due to the village party bandi. That the informant’s family members are supporters of the present Village Pradhan and are close to each other while the applicant’s family opposed in last Village Pradhan election as such on the influence of the present Village Pradhan, the applicant is named in the present case crime. That there was a dispute between the informant’s family and the named accused of the case crime i.e. Monu Nishad and they fought with each other on 13.10.2023. That the applicant is a friend of Monu Nishad i.e. named accused of the case crime, due to which on instructions of the Village Pradhan, the applicant is named in the case crime. That neither the deceased has been murdered by the applicant nor he was planned for the murder of the deceased along with other accused but the applicant has been falsely implicated in the case crime. That due to malafide intention, the informant for her self-satisfaction on the instruction of political enmity of the applicant’s family lodged the first information report against the applicant, while he has not committed any offense as alleged against him. That the applicant has no concern with the murder of the deceased in any manner as alleged by the concerned police and the allegation against the applicant and also the prosecution story is totally against truth and is not reliable in manner. That neither the applicant has a motive nor has any reasonable motive been assigned to him to commit the crime in question. That there is no credible evidence on record that could show that the applicant is guilty or committed the crime in question and the evidence available on the record itself shows that no prima-facie offense under Sections 302, 34, 120-B of I.P.C. at Police Station – Gosainganj, District – Sultanpur is made out against the applicant. That the applicant is in jail since 20.10.2023 without committing any offense. That apart from the present case crime, the below-mentioned cases have been lodged against the applicant:- Case Crime No. 95 of 2023 lodged under Sections 354, 506 of I.P.C. and 8 of The Protection of Children from Sexual Offences Act, 2012 registered at Police Station - Gosainganj, District - Sultanpur, in which the applicant has been acquitted by the court below vide order dated 11.12.2023. The photocopy of the order dated 11.12.2023 passed by the learned court below is being annexed as Annexure No. 06 to this affidavit. Case Crime No. 379 of 2020 lodged under Sections 147, 148, 149, 452, 323, 504, 506, 188, 269 of I.P.C. and 3 of The Epidemic Diseases Act, 1897 registered at Police Station - Gosainganj, District - Sultanpur. The applicant has no information regarding said case crime and till yet he has not received any notice or summon. That apart from the abovementioned cases, as per best knowledge of the applicant has no criminal history. That the applicant moved bail application No. 3631 of 2024 before the learned Sessions Judge, Sultanpur and his bail application has been rejected by the court concerned on 08.12.2023. The free certified copy of the bail rejection order dated 08.12.2023 passed by the court below is being annexed as Annexure No. 07 to this affidavit. That there is no chance of the applicant absconding or tempering with the prosecution witnesses. That the applicant is ready to furnish the security and bond and also undertakes that he will be never misuse the liberty of bail. That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail in connection with Case Crime No. 426 of 2023 under Sections 302, 34, 120-B of I.P.C. registered at Police Station – Gosainganj, District – Sultanpur, in the interest of justice.


I, Shivam Sardar Bhartiya aged about 28 years son of Shri Phulchand Bhartiya resident of Village - Pandeypur, Post - Sikrara, Alishahpur, District – Jaunpur, Education – Literate, Occupation – _________, do hereby solemnly affirm and state on oath as under:- That the deponent is the _________/pairokar of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such he is fully conversant with the facts of the case and deposed as under. The photo verification slip issued by the Awadh Bar Association, Lucknow of the deponent is affixed on the affidavit and his ID proof is enclosed with the affidavit. That the deponent further declared that the contents of the bail application have been explained by the counsel of the applicant in Hindi and as such he is fully conversant with the facts of the case deposed as under. That 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 this is the first bail application before this Hon'ble Court. No any other bail application is pending before this Hon'ble Court or rejected by this Hon'ble Court. That brief fact of the case is that a first information report was lodged against the applicant and 10 other persons on 22.02.2024 at 15.37 hours by Renu daughter of Shri Vinod Kumar resident of Village - Gopalpur, Post - Mokalpur, Police Station - Akhand Nagar, District – Sultanpur (hereinafter referred to as ‘informant’) under Sections 147, 148, 452, 323, 504, 506, 427, 302 of I.P.C. and 3(2)(v) of the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989 (Amendment, 2015) at Police Station – Akhand Nagar, District – Sultanpur regarding incident dated 21.02.2024. The certified typed copy of the first information report dated 22.02.2024 is being annexed as Annexure No. 01 to this affidavit. That according to the first information report lodged on 21.02.2024, around 6.00 PM, one Jagdish parked his motorcycle in front of the informant’s house and when he was restrained he abused the informant’s family. Later on, around 06.30 PM, Jagdish came with other accused including the applicant along with weapons and after abusing by caste, beaten several persons due to which the informant and some others were injured. When one Surya Pratap was brought to the C.H.C., Akhand Nagar, he was declared dead. That the inquest report of the deceased body was prepared by the concerned police on 21.02.2024 in the presence of several villagers. That the body of the deceased was brought to the P. M. House, Sultanpur for conducting a post-mortem on 22.02.2024, where post-mortem was conducted and the cause of the death was ascertained as “Hamarrage and Shock, due to antemortem injuries.”. The photo/ typed copy of the post-mortem report dated 22.02.2024 is being annexed as Annexure No. 02 to this affidavit. That the version of the first information report is totally false and baseless and the same depends upon the concocted story as such nothing happened as alleged by the informant in her first informant report. Here it is relevant to mention that the applicant has not committed any offense as alleged against him. That the alleged injured were brought to the C.H.C., Akhand Nagar, District - Sultanpur on 22.02.2024 for the initial treatment, in which the duration of the injury was noted as 1 or 2 days delay, which is not collaborated with the prosecution story. The photo/typed copy of the injury report of the injured dated 22.02.2024 is being annexed as Annexure No. 03 to this affidavit. That the investigating officer recorded the statement of the informant under Section 161 of Cr.P.C. on 23.02.2024 in which the informant almost repeated her first information report. The typed copy of the statement of the informant dated 22.02.2024 is being annexed as Annexure No. 04 to this affidavit. That the statements of the witnesses of the alleged case crime were recorded by the concerned police, in which they have been given contradictive statements, which itself creates doubt upon the prosecution story. The typed copy of the statements of the witnesses of the case crime are being annexed as Annexure No. 05 to this affidavit. That on the applicant was arrested by the concerned police on 24.02.2024 from his home but for showing his good work, his arrest was shown in a forged and fabricated arresting memo dated 24.02.2024. Two other accused were also arrested by the concerned police on the same day. That thereafter, the confessional statements of the co-accused and applicant have been written/ prepared by the Investigating Officer on 24.02.2024 as per his wish and tried their best to collaborate with the alleged incident and witnesses under section 161 Cr.P.C. only to prove the offense against the applicant whereas the applicant has not committed any offense. The typed copy of the confessional statement of the applicant and co-accused dated 24.02.2024 is being annexed as Annexure No. 06 to this affidavit. That the confessional statements of the arrested co-accused and applicant were recorded by the concerned police on 24.02.2024 under the life threat, in which the applicant said everything as narrated by the concerned police. That it is most humbly submitted that the applicant is innocent and he has falsely been implicated by the informant in the instant case and there is no evidentiary value in the eye of the law relating to the confessional statements given by the arrested accused. That on the pointing of others accused of the case crime, the alleged murder weapon was recorded by the concerned police and nothing has been recovered from the possession or pointing of the applicant. That the informant has not assigned any role to the applicant as she assigned to all accused, who were present at the time of the alleged incident. That on the basis of such a story, which was narrated by the investigating officer himself, without proper investigation of the case crime, submitted the charge sheet No. 52 of 2024 against the applicant under Sections 147, 148, 452, 323, 504, 506, 427, 302 of I.P.C. and also against others under other sections also on 16.04.2024. The photocopy of the charge sheet submitted on 16.04.2024 is being annexed as Annexure No. 07 to this affidavit. That the real story is that the applicant has no concern with the alleged offense and he has been falsely implicated by the informant due to the village party bandi. That the informant’s family members are supporters of the present Village Pradhan and are close to each other while the applicant’s family opposed him in the last Village Pradhan election as such on the influence of the present Village Pradhan, the applicant is named in the present case crime. That there was a dispute between the informant’s family and one Jagdish but being his well-wisher due to which on instructions of the Village Pradhan, the applicant is named in the case crime. That neither the deceased has been murdered by the applicant nor he was planned for the murder of the deceased along with other accused but the applicant has been falsely implicated in the case crime. That due to malafide intention, the informant for her self-satisfaction on the instruction of political enmity of the applicant’s family lodged the first information report against the applicant, while he has not committed any offense as alleged against him. That the applicant has no concern with the murder of the deceased in any manner as alleged by the concerned police and the allegation against the applicant and also the prosecution story is totally against truth and is not reliable in manner. That neither the applicant has a motive nor has any reasonable motive been assigned to him to commit the crime in question. That there is no credible evidence on record that could show that the applicant is guilty or committed the crime in question and the evidence available on the record itself shows that no prima-facie offense under Sections 147, 148, 452, 323, 504, 506, 427, 302 of I.P.C. at Police Station – Akhand Nagar, District – Sultanpur is made out against the applicant. That the applicant has been in jail since 24.02.2024 without committing any offense. That apart from the present case crime, as per the best knowledge of the applicant, there is no any other criminal history against him. That when the applicant was arrested by the concerned in connection with the present case, he was ill and under treatment. But, there is no proper treatment given to the applicant in jail, due to which his life is in danger. That on 04.04.2024, an application was moved before the learned trial court for providing the proper and better treatment to the applicant as no proper treatment is being given to the applicant in jail but nothing has been done by the jail authority despite the learned court below directed him to provide medical facility to the applicant. The photo/typed copy of the applicant moved by the applicant before the learned trial court on 04.04.2024 is being annexed as Annexure No. 08 to this affidavit. That after passing long time, when the proper and better treatment has not been given to the applicant while the same is his fundamental right, then another applicant was moved on 07.05.2024 before the learned trial court for providing the proper and better treatment to the applicant as no proper treatment is being given to the applicant in jail but nothing has been done by the jail authority. The photo/typed copy of the applicant moved by the applicant before the learned trial court on 07.05.2024 is being annexed as Annexure No. 09 to this affidavit. That without the proper and better treatment, the life of the applicant is in danger and he would die in jail. That the applicant moved bail application No. 933 of 2024 before the learned Special Judge, S. C. & S. T. (P.A.) Act, Sultanpur, and his bail application have been rejected by the court concerned on 13.06.2024. The free certified copy of the bail rejection order dated 13.06.2024 passed by the learned court below is being annexed as Annexure No. 10 to this affidavit. That there is no chance of the applicant absconding or tempering with the prosecution witnesses. That the applicant is ready to furnish the security and bond and also undertakes that he will be never misuse the liberty of bail. That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail in connection with Case Crime No. 38 of 2024 under Sections 147, 148, 452, 323, 504, 506, 427, 302 of I.P.C. registered at Police Station – Akhand Nagar, District – Sultanpur, in the interest of justice.


I, Smt. Bhanmati aged about 39 years wife of Kukaee Nishad resident of Village - Baruie, Police Station - Gossainganj, District - Sultanpur, Qualification – Illiterate, Occupation – Housewife, the deponent do hereby solemnly affirm and  state on oath as under:- That the deponent is the mother/pariokar of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such she is fully conversant with the facts of the case and deposed as under. The ID Proof of the deponent is enclosed and her photo verification slip issued by the Oudh Bar Association, Lucknow is affixed to the affidavit. That the deponent further declares that the contents of the affidavit have been explained in Hindi by the counsel of the applicant to her as such he 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 this is the first bail application on behalf of the applicant before the Hon'ble Court and no other bail application is pending before in any court of law on his behalf. That the facts giving rise to the present case are being stated in brief hereinafter. That the applicant has falsely been implicated in case crime No. 274 of 2023 lodged under Sections 498A, 323, 304B of I.P.C. and 3/4 Dowry Prohibition Act, 1961 registered at Police Station – Gossainganj, District – Lucknow on 21.06.2023 at 12.51 hours, against the applicant. The first information report is lodged by Shri Udayraj son of Late Ramdas resident of Village - Kuchhmuchh, Police Station - Domuhan, District - Sultanpur (hereinafter referred to as ‘informant’) regarding an incident dated 20.06.2023. The certified copy of the first information report dated 21.06.2023 is being annexed herewith as Annexure No. 1 to this Affidavit. That the informant stated in his first information report that the marriage of the applicant and his daughter namely Karishma alias Reshma (hereinafter referred to as ‘deceased’) was solemnized around one year ago. The deceased was tortured for the dowry and in the night of 20.06.2023, the applicant murdered the deceased by hanging her. That according to the first information report, the deceased was hanged by the applicant in the night of 20.06.2023 but the the first information report was lodged around more than 36 hours later, after getting legal advice. That it is relevant to mention here that the informant planned and falsely implicated the applicant to get financial benefits. Thereafter on the basis of legal advice, the first information report has been lodged against the applicant on wrong and baseless facts. That the inquest report was prepared by the concerned police in the presence of the Panchan and also in the presence of the informant and other persons on 21.06.2023. That the body of the deceased was sent for the post-mortem on 21.06.2023 at District Hospital, Sultanpur wherein the post-mortem was done by doctors, and the cause of death was ascertained as ‘Anti-mortem hanging”. The photo/type copy of the post-mortem report dated 21.06.2023 is being annexed herewith as Annexure No. 2 to this Affidavit. That according to the post-mortem report, the time of death of the deceased was about one day back, which is also not collaborated with the prosecution story. That the statement of the informant was recorded by the concerned police under section 161 Cr.P.C. on 21.06.2023 and therein the informant repeated his first information report version and tried to develop his prosecution story to fill the loopholes of the prosecution story to send the applicant behind the bar merely being the husband of the deceased. The typed copy of the statement of the informant dated 21.06.2023 is being annexed herewith as Annexure No. 3 to this Affidavit. That on the basis of the false first information report, the applicant was arrested by the concerned police from his house on 22.06.2023. That the statement of the mother of the deceased was also recorded by the concerned police under section 161 Cr.P.C. on 03.07.2023 in which they repeated the version of the informant in their own words and tried their best to falsely implicate the applicant and his family members in said case crime. The photocopy of the statement of the mother of the deceased dated 03.07.2023 is being annexed herewith as Annexure No. 4 to this affidavit. That the real fact of the case is that the marriage of the applicant and the deceased was solemnized without permission of the parents of the deceased i.e. their marriage was a love marriage, which was solemnized in a temple That nothing was demanded from the applicant from the informant and his family as dowry after the marriage as alleged against the applicant as the applicant and deceased solemnized their marriage against the WILL of the informant. That initially the relationship between the applicant and the deceased was good enough and there was no dispute between the applicant and the deceased. That later on, the applicant came to know that the deceased was a mentally ill lady and not able to make good decisions, even though she was a short-tempered lady. That on 20.06.2023, the deceased fought with the applicant and due to the aforementioned reason, the deceased was upset and committed suicide due to her own reasons. That here it is relevant to mention that the deceased was a short-tempered lady and she became more aggressive and also not in a position to make good decisions due to her anger as well mental illness and committed suicide. That the applicant immediately informed the concerned police and informant after said unfortunate incident. That the informant due to extraneous reasons lodged the first information against the applicant and his family members after getting legal advice just for his satisfaction while he is well aware that his daughter committed suicide for her own reasons due to her mental illness. That the trial has been initiated and on 09.11.2023, the informant was examined by the learned trial court as P.W. - 1, in which he himself stated that the applicant has never demanded dowry as the marriage of the applicant and deceased was a love-marriage and also stated that the deceased was mentally ill due to which she committed suicide. The photo/typed copy of the examination of the informant/P.W. - 1 is being annexed herewith as Annexure No. 5 to this Affidavit. That on 23.11.2023, the wife of the informant was examined by the learned trial court as P.W. - 2, in which she herself supported the version of the informant i.e. P.W. - 1 and stated that the applicant has never demanded dowry as the marriage of the applicant and deceased was a love-marriage and also stated that the deceased was mentally ill due to which she committed suicide. The photo/typed copy of the examination of the wife of the informant/P.W. - 2 is being annexed herewith as Annexure No. 6 to this Affidavit. That the applicant is being the husband of the deceased falsely implicated in the said case crime by the informant while the deceased committed suicide due to her mental illness which has been confirmed by the informant and his wife. 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 offense is made out against the applicant. That the applicant has no motive to commit the alleged crime and a false motive which was given in the case, is cooked and fabricated by the concerned police. That since the applicant has not committed any offense as alleged but he has been falsely implicated in the case by the informant with malafide intention. That no involvement in the said case as alleged in the first information report, the applicant has no reason to murder the deceased. 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 a common man of society. He has never been involved in any criminal activities ever. That the applicant has no criminal history except the aforesaid false case and is not likely to hope in the future to commit any offense. 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/accused is in jail being the husband of the deceased since   22.06.2023 without committing any crime. 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 Hon’ble Court. That the applicant is ready and willing to file adequate surety as the Hon’ble Court may deem fit and proper in the circumstances of the case. That the applicant had applied for bail application bearing Bail Application No. 249 of 2024 but the same has been rejected by the Sessions Judge, Sultanpur on insufficient grounds vide order dated 21.02.2024. The certified copy of the bail rejection order dated 21.02.2024 is being annexed herewith as Annexure No. 7 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 connection with Case Crime No. 274 of 2023 under Sections 498A, 304B of I.P.C. and 3/4 Dowry Prohibition Act, 1961 registered at Police Station – Gossainganj, District – Lucknow, during the pendency of the case.


I, Arvind Kumar aged about 28 years son of Shri Shiv ratan Chaudhary resident of Village – Mulihamau, Police Station – Jaisinghpur, District – Sultanpur, Religion – Hindu, Education – Literate, Occupation – Agriculture, do hereby solemnly affirm and state on oath as under :- That the deponent is the brother of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such he is fully conversant with the facts of the case and deposed as under. The ID Proof of the deponent is enclosed and her photograph is affixed on the affidavit. That this is the first bail application of the applicant before this Hon'ble Court.  No any other bail application pending before this  or rejected by this . That brief facts of the case is that a first information report has been lodged against applicant on 20.03.2024 by informant namely Suryapal Verma bearing Case Crime No. 130 of IPC under Sections 354A, 384, 506 of IPC at Police Station – Jaisinghpur, District – Sultanpur.  The photocopy of the first information report dated 20.03.2024 is being annexed as Annexure No. 01 to this application. That according the first information report the informant stated in his first information report that the applicant molest his daughter namely Neema (hereinafter referred to as ‘victim’) and also made a video. When the victim restrained for recording of the video then applicant demanded Rs. 1 lac for deleting the video or offered to marry with victim. The applicant further threaten to murder the informant. That the statement of the informant under Section 161 Cr.P.C. has been recorded on 21.03.2024 by the concerned police, in which he almost repeated the contents of the first information report. The typed copy of the statement of the informant under Section 161 Cr.P.C. dated 21.03.2024 is being annexed herewith as Annexure No. 02 to this application. That the statement of victim under Section 161 Cr.P.C. recorded by the concerned police, in which she stated that that she has love relation with the applicant from last 6 years. The applicant and victim fight several times but later on everything becomes normal. The victim further alleged that 7 months ago, the applicant made a video of the victim and for which he demanded Rs. 1 lac and on denial of giving money the applicant threaten viral the video. The typed copy of the statement of victim under Section 161 Cr.P.C. of victim is being annexed as Annexure No. 03 to this application. That the victim brought for medical where the victim and informant both have not given consent for medical. The denial from the medical by the informant and victim itself creates doubt upon the prosecution story. The photocopy of the denial of the medical of the victim is being annexed herewith as Annexure No. 04 to this affidavit. That the statement of victim under Section 164 Cr.P.C. recorded before the concerned court on 23.03.2024, in which she changed her statement of the 161 of Cr.P.C. and she admitted that she had love relation with the applicant from last 6 years and stated that 6 months ago, when they were in physical relation, the applicant recorded their video and after knowing the said fact, the victim broken the mobile of the applicant. The victim herself stated that she was given her consent for sexual relationship not for recording the video. The typed copy of the statement of victim under Section 164 Cr.P.C. dated 23.03.2024 is being annexed as Annexure No. 05 to this application. That after recording the statement of the victim under Section 164 of Cr.P.C., the concerned police added the Sections 323, 376 of IPC, while nothing is against the applicant. That the real story of the case is in nutshell: the victim and applicant have fallen in love since long back and they met regularly with each other and they both have also sexually active. When this fact came to knowledge of the informant and his family then they came to applicant’s house and restraining the applicant and victim to continue their love relation. The informant also threatens the applicant to face consequences of having relation with his daughter. That the whole story cooked by the informant and their family members against the applicant and explained by the concerned police after knowing everything. That the informant is not the ocular witness and prosecution story as narrated therein highly improbable, improper and unnatural and unbelievable for prudent man. The victim herself admitted she has given consent for sexual relation. That without proper investigation of the case, the investigating officer submitted charge sheet No. 133 of 2024 under Sections 323, 376, 354A, 384, 506 of IPC on 15.04.2024 and the magistrate takes cognizance against the applicant. That a false story cooked up by the concerned police and the informant and his family members for obtaining the money form the state government, which is given to the rapped victim. That there is no any evidence against the applicant to connect him with the aforesaid 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 and their family members in malafide intention while the victim went with the applicant with her own WILL and solemnized marriage with the applicant. That no any involvement in the said case as alleged in first information report, the applicant has not committed any offence, the victim is consenting party and the relation between both is mutual consent. That the applicant moved bail application bearing No. 2316 of 2024 before Additional Sessions Judge, FTC – 1, Sultanpur and his bail application has been rejected by the court concerned on 15.09.2024. The free certified copy of the order dated 15.09.2024 passed by court concerned is being annexed as Annexure No. 06 to this application. That the applicant in jail since 24.03.2024 without committing any offense as alleged against the applicant. That it is settled law that in every case of rape, the act of sexual intercourse must be forcible and without consent of the lady. Here in case, the victim having love relation and they were in sexual relation with her consent. That here it is relevant to submit in view of the law settled by the Hon'ble Apex Court as well as different Hon'ble High Courts of the country that the allegation of rape after having a long standing relation does not come under category of rape. The law is now well settled that even the statement recorded under Section 164 is not always to be taken as gospel truth and same needs to cross verified and checked from other sources. That here it is relevant to mention that the Section 375 of IPC related to the definition of the Rape. Here in present case, the essential element of the Rape i.e. is missing i.e. cons the applicant has physical relation with the victim with her consent. That the victim having love and affection and she had sexual relation with the applicant with her own free WILL and given consent for the same to the applicant, but suddenly under the pressure of the her father i.e. informant, she lodged the first information report against the applicant. That the applicant has not committed any crime none of the sections as mentioned in the first information report is attracted against the applicant. The statement of the victim herself evident that everything which happened was consensual and the entire story of alleged rape has been levelled by the victim under pressure of the informant. That the applicant promised to marry with the victim and does not broken his promise and still ready to marry with the victim and not committed any offense as alleged by her 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 and their family members in malafide intention while the victim went with the applicant with her own WILL and solemnized marriage with the applicant. That no any involvement in the said case as alleged in first information report, the applicant has not committed any offence, the victim is consenting party and the relation between both was on mutual consent. That the applicant has no criminal history except the aforesaid false case and not likely to hope in future to commit any offence. That there is no chance of the applicant absconding or tempering with the prosecution witnesses. That the applicant is ready to furnished the security and bond and also undertake that he will be never misused liberty of bail. That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail in connection with Case Crime No. 130 of 2024 under Sections 323, 376, 354A, 384, 506 of IPC registered at Police Station – Jaisinghpur, District – Sultanpur, in the interest of justice.


I, Suraj Saroj aged about 26 years son of Shri Indra Pal Saroj resident of Village - Chiguda, Post - Sarai Shankar, Police Station - Kohdaur, Education – ___________, Occupation – ___________, do hereby solemnly affirm and state on oath as under:- That the deponent is the nephew/pairokar of the applicant and duly authorized by the applicant to file the aforesaid application before this Hon'ble Court and as such he is fully conversant with the facts of the case and deposed as under. The photo verification slip issued by the Awadh Bar Association, Lucknow of the deponent is affixed on the affidavit and his ID proof is enclosed with the affidavit. That the deponent further declared that the contents of the bail application have been explained by the counsel of the applicant in Hindi and as such he is fully conversant with the facts of the case deposed as under. That 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 this is the first bail application before this Hon'ble Court. No any other bail application is pending before this Hon'ble Court or rejected by this Hon'ble Court. That brief fact of the case is that a first information report was lodged against the applicant on 15.01.2022 at 23.10 hours by Dhananjay Tiwari, District Manager, P.C.F., Pratapgarh (hereinafter referred to as ‘informant’) under Section 409 of I.P.C. at Police Station – Kotwali Nagar, District – Pratapgarh. The certified and typed copy of the first information report dated 15.01.2022 is being annexed as Annexure No. 01 to this affidavit. That the informant stated in his first information report that a first information report was lodged against the applicant on 14.11.2021 and in the absence of the applicant, the godowns owned by the applicant were seized by the Committee constituted by the District Magistrate. Later on, when the godowns were opened by the Committee and the stock was compared with the stock register then it was found that 8842 bags of urea and 2 boxes (24 liters) of nano urea were short. Therefore, the Assistant Commissioner and Assitant Registrar, Cooperative vide its order dated 14.01.2022 directed the informant to lodge the first information report against the applicant. That here it is relevant to mention that the allegations levelled against the applicant are false and incorrect as the applicant has not been involved in an offense alleged by the informant. That the informant lodged the first information report on the basis of a false and incorrect fact and the same depends upon the concocted story as such nothing happened as alleged by him in his first informant report. That the Investigating Officer recorded the statement of the informant under Section 161  Cr.P.C. on 15.01.2022 in which the informant repeated his first information report version. However, the applicant has not committed any offense as stated by him. The typed copy of the statement of the informant dated 15.01.2022 is being annexed herewith as Annexure No. 02 to this affidavit. That the applicant was in jail in connection with Case Crime No. 931 of 2021 under Sections 409, 419, 420, 467, 468, 471 of I.P.C. related to the Police Station – Kotwali City, District – Pratapgarh since 11.01.2022 as such the confessional statement of the applicant has been written/ prepared by the Investigating Officer on 27.01.2022 as per his wish and tried their best to collaborate with the alleged incident and witnesses under section 161 Cr.P.C. only to prove the offense against the applicant whereas the applicant has not committed any offense. The typed copy of the confessional statement of the applicant dated 2777.01.2022 is being annexed as Annexure No. 3 to this affidavit. That it is most humbly submitted that the applicant is innocent and he has falsely been implicated by the informant in the instant case and there is no evidentiary value in the eye of the law relating to the confessional statements given by the arrested accused. That the Investigating Officer recorded the further statement of the informant under Section 161  Cr.P.C. on 31.01.2022 in which the informant improved facts to build his case against the applicant by collaborating his statements with other witnesses and documents, which were prepared against the applicant while the applicant has not committed any offense as stated in the first information report and statements of the informant. The typed copy of the further statement of the informant dated 31.01.2022 is being annexed herewith as Annexure No. 04 to this affidavit. That the Investigating Officer recorded the second further statement of the informant under Section 161  Cr.P.C. on 24.11.2022 in which the informant again tried to improve his prosecution story and tried to fill the loopholes of allegations, which are so far from the facts and truth. The typed copy of the second further statement of the informant dated 24.11.2022 is being annexed herewith as Annexure No. 05 to this affidavit. That on the basis of such a story, which was narrated by the investigating officer himself, without proper investigation of the case crime, submitted the charge sheet against the applicant bearing charge sheet No. 140 of 2022 under Sections 409. 120-B of I.P.C. on 20.04.2022. The photocopy of the charge sheet dated 20.04.2022 is being annexed as Annexure No. 06 to this affidavit. That the real story is that the applicant has no concern with the alleged offense and he has been falsely implicated by the informant due to false and incorrect facts merely on presumption. That the applicant has been falsely implicated in the case crime by the informant. Earlier another first information report dated 14.11.2021 bearing Case Crime No. 931 of 2021 under Sections 409, 419, 420, 467, 468, 471 of I.P.C. related to the Police Station – Kotwali City, District – Pratapgarh lodged against the applicant. That when the names of higher officials were about to come to light in the said matter thereafter in a planned manner, the applicant was falsely implicated in the said case even though he had not committed any crime as alleged against him. That the applicant has no concern with the missing urea in any manner as alleged by the informant as well as concerned police and the allegation against the applicant and also the prosecution story is totally against truth and is not reliable in manner. That the mother of the applicant is a paralyzed old lady and alone at home and no one to take care of her and also she is not able to go for her treatment, which is going on at District Prayagraj. The photocopy of the medical records of the mother of the applicant is being annexed as Annexure No. 07 to this affidavit. That the children of the applicant are too small and their life and career will be ruined if the applicant languishes in jail, without committing any offense. That there is no credible evidence on record that could show that the applicant is guilty or committed the crime in question and the evidence available on the record itself shows that no prima-facie offense under Section 409 of I.P.C. at Police Station – Kotwali Nagar, District – Pratapgarh is made out against the applicant. That the applicant has been in jail since 11.01.2022 without committing any offense. That till date the charges have not been framed against the applicant or other accused while the applicant is in jail since 11.01.2022 and there is no chance for framing of charges. That prior to the instant case crime, the applicant was also falsely implicated in another Case Crime No. 931 of 2021 under Sections 409, 419, 420, 467, 468, 471 of I.P.C. related to the Police Station – Kotwali City, District – Pratapgarh, in which the applicant has been granted bail by this Hon'ble High Court on 28.08.2024. The photocopy of the order dated 28.08.2024 passed by this Hon'ble High Court is being annexed as Annexure No. 08 to this affidavit. That the four co-accused of the case crime namely Rajesh Kumar Patel, Dinesh Kumar Maurya, Dinesh Kumar Saroj, and Sanjeev Kumar have been granted bail by this Hon'ble High Court respectively on 11.07.2022, 18.10.2022, 07.12.2022 and 20.12.2022. The photocopies of the bail orders granted to the co-accused of the case crime are being annexed as Annexure No. 09 to this affidavit. That apart from the abovementioned case, as per the best knowledge of the applicant, he has no criminal history. That the applicant moved bail application No. 3631 of 2024 before the learned Sessions Judge, Pratapgarh, and his bail application was rejected by the court concerned on 06.05.2022. The free certified copy of the bail rejection order dated 06.05.2022 passed by the court below is being annexed as Annexure No. 10 to this affidavit. That there is no chance of the applicant absconding or tempering with the prosecution witnesses. That the applicant is ready to furnish the security and bond and also undertakes that he will be never misuse the liberty of bail. That in view of the above, it would be expedient and necessary in the interest of justice that the applicant be enlarged on bail in connection with Case Crime No. 39 of 2022 under Section 409 of I.P.C. registered at Police Station – Kotwali Nagar, District – Pratapgarh, in the interest of justice.


I, Rakesh Yadav aged about 36 years son of Shri Kanhaiyalal resident of Ramganj, Ramganj, District - Pratapgarh, Religion – Hindu, Education – Literate, Occupation – _________, deponent do hereby solemnly affirm and state as under:- That the deponent is the brother/pairokar of the applicant and duly authorized by him and as such he is fully conversant with the facts of the case and deposed as under. The photograph of the deponent is affixed on the affidavit and his ID proof is enclosed with the affidavit. That it is relevant to mention here that the present application of bail is still pending before this Hon'ble High Court for consideration since its filing. That the applicant is in jail around 9 months without committing any offense as such the father of the applicant is in deep mental trauma and suffering from acute depression. That the father of the applicant also had heart disease and recently he was admitted to hospital after a major heart attack, if the applicant is not released on bail, the father of the applicant would die. That due to the non-disposal of the instant bail application, which is liable to be allowed in view of the facts and circumstances of the case, the applicant and family members are suffering. That due to the non-disposal of the bail application filed by the applicant, the applicant is suffering irreparable loss and injury which cannot be compensated in any manner as the opposite party No. 2 falsely implicates the applicant in said case crime. That due to the pendency of the aforesaid bail, the applicant is also suffering a lot as mentally and physically. That for the facts, reasons and circumstances stated hereinabove, it is most respectfully prayed that this Hon’ble Court may kindly be pleased to enlarge the applicant on bail in connection with Case Crime No. 206 of 2022 under sections 354 (Kha), 504, 506, IPC and 7/8 of The Protection of Children from Sexual Offences Act, 2012 and 67 of Information Technology Act, registered at Police Station - Aaspur Devsara, District Pratapgarh, in the interest of justice.