IN THE COURT OF SESSIONS FOR GREATER BOMBAY CRIMINAL
APPELLATE JURISDICTION

ANTICIPATORY BAIL APPLICATION NO. _______ OF 20

………………………………………………………………
Resi at ___________ …….. Petitioner

V/s

1. State of Maharashtra at the instance of The Inspector of Police In-
charge of ________Police Station …….. Respondent

CRIMINAL ANTICIPATORY BAIL APPLICATION UNDER SECTION 438
OF THE CRIMINAL PROCEDURE CODE, 1973.

To
THE HON’BLE PRINCIPAL JUDGE AND HIS COMPANION JUDGES OF
THIS HON’BLE COURT.THE HUMBLE PETITION OF THE PETITIONER
ABOVE
NAMED:MOST RESPECTFULLY SHEWETH:

1. The petitioner is a citizen of India. The petitioner is about ___years
old and is unmarried. The petitioner is a permanent resident of

Mumbai, residing at the address as mentioned in the cause title
since birth. The petitioner is the son of ____________, who is the
co-owner of the aforesaid premises. The petitioner’s father shares
the said premises amongst others with one of the petitioner’s
……………………..
The petitioner’s father and the said…………………………. are also
partners in a firm called M/s. _____________ situated at
_______________________.
2.     The petitioner’s …………………………………………….. are
involved in various civil disputes relating to the said partnership firm,
the residential premises and other commonly held properties. There
are many cases and proceedings pending in different courts in
Mumbai relating to the same. The said ………………… has also time
and again dragged the petitioner’s father and his family to the
Criminal courts and/or police station. However on each of the
occasions the said ………………… has met with no success but
continues to harass the petitioner, his parents and other family
members by lodging false, frivolous and mischievous complaints one
after the other.
3.     The petitioner understands that the said ………………………. has
filed a complaint on or around _________ in the ____________
under Sections _____________ of the Indian Penal Code against the
petitioner’s ……………………….. of his family members including the
petitioner
………………………………………………………………………………
…………. The petitioner says and submits that the said complaint has
been filed by the said ……………… as a continuation of the process
of harassment and vendetta against the petitioner’s father and with a
view to coerce and threaten the petitioner into submission in relation
to the civil disputes pending between the petitioner and the said
………………… The petitioner states that on the said date of
__________, the said …………………… had stolen the petitioner’s
mobile phone and the petitioner had lodged an N.C. complaint (being
complaint No._________ of 20………) at the _________ police
station. The complaint by ………….. is merely a counter blast.
4.     The petitioner apprehends that on the basis of the allegations
contained in the said counter complaint of …………………. the police

authorities are likely to arrest / detain him. The petitioner is a
respectable citizen of India and is well known in the locality where he
stays. The petitioner is an educated youth being _________ (mention
the educational qualifications). The petitioner is an Income-tax
assessee. The petitioner has acquired his reputation which would be
tarnished if he is arrested and/or detained. The petitioner has done
nothing to warrant that his reputation to be harmed at the behest of
his disgruntled uncle, i.e. said Mr. …………………
5.     The petitioner says that the nature of disputes between his father
and his uncle are civil and the courts are fully seized of the same and
as a law abiding citizen of the country the petitioner shall abide by the
verdict of the Honorable courts.
6.     The petitioner says and submits that there is no allegation against
him requiring custodial interrogation and therefore prays that in the
event of the petitioner’s arrest by the _____________Police Station
on the basis of the aforesaid allegations made by
……………………….., this Honorable court be pleased to release him
on Bail on such terms and conditions and on such amount as this
Honorable court may deem fit and proper. The petitioner undertakes
to extend his fullest co-operation to the police and report at the police
station as and when required for any investigation. The petitioner has
his roots in Mumbai and is living in Mumbai since his birth. The
petitioner’s father is the co-owner of immovable property
_________________________ (describe the immovable property
and give its address in detail). The petitioner, his brother and his
parents are all residing together at ______________________ (Give
residential address in full). There is no apprehension of the petitioner
absconding. There is no threat of the petitioner tampering with the
evidence in any manner whatsoever.
The petitioner therefore prays:

a.     that in the event of the arrest of the petitioner by the
__________ Police station on charges arising out of the
complaint made by ………………………………., the Inspector
of Police be directed to release the petitioner on bail of such
amount and on such terms and conditions as this Honorable
court may deem fit and proper;

b.    for such other and further reliefs as may be deemed fit and
proper in the facts and circumstances of the case.
Mumbai dated this ________ day of _________, 20………….
Petition drawn by: Petitioner
Advocate for the Petitioner

VERIFICATION
I.        …………………………………………………………, the petitioner
above-mentioned, do solemnly affirm that what is stated in this
petition save and except legal submissions is true to my personal
knowledge.
Solemnly affirmed at Mumbai on) this ______ day of
……………………………………)

Petitioner

Before me

Advocate for the petitioner.