IN THE HONBLE DISTRICT AND SESSION COURT
AT……………………Cr MP (M) No:______ 20…
…………………………………………………………..Applicant/Petitioner
VERSUS
……………………………………………………….Respondents
Application under Section 439 CrPC for the grant of Bail
Respectfully Sheweth:
1. That the accused Sh. _______________________________ of the
applicant has been involved in a false and frivolous case by one Sh.
___________________________ by lodging a complaint/FIR No.
_________________________________________________ dated
____________ under Sections ________________ of IPC with the
………….: _______. The accused has been arrested by the Police of
Police Station: ___________________________ subsequent to the above
complaint.

2. That it is submitted that the allegations made against the accused are
false, frivolous and vexatious and lack in the material substance. The
accused has nothing to do with the alleged offences. The accused belongs
to a very reputed family in his locality. The allegations are that _________

3. That the accused is a permanent resident of

_______________________________________ and earning livelihood by
_______________________________________. The accused has his old
parent’s dependent upon him and the accused is the only bread earner for
the family.

4. That the accused is innocent and has been involved falsely due to the
personal grudge to settle the score against the accused by the
______________________________ due to ________. ________It is
submitted that the complainant is an influential and high-handed person.

5. That by getting the accused arrested the accused has been deprived of
his valuable fundamental right of liberty by abuse of legal provisions and
process of law by the complainant.

6. That the accused is willing to furnish surety and bail bonds to the
satisfaction of this Hon'ble court on being ordered to be released on bail.
The accused is also willing to join the investigations and bind himself by the
terms and conditions laid down by the law or by this Hon'ble court. It is
further submitted that the accused is not at all required for the
investigations and the investigations are over. However, if the accused is
required for investigation, the applicant undertakes that the accused will be
present as and when required in accordance with the law.

7. That neither any recovery is to be effected from the accused nor is the
accused in a position to temper with the prosecution evidence. The
accused will associate with the investigation whenever required to do so.

8. That the petitioner submits that no such application on behalf of the
accused on the same or similar grounds has been filed or is pending in any
other court.

9. That the accused has immovable property in the said village and is
___________________self-employed in the reputed government job and
there is no chance of his jumping over the bail.

10. That the accused further undertakes not to tamper with any prosecution
evidence or terrorize the witnesses.

11. The accused undertakes not to leave the jurisdiction of state of ……….
and India without the orders of the Court.
It is, therefore, most respectfully prayed that:-
(a) that the accused may kindly be ordered to be released on bail and this
application for bail may kindly be allowed;
b) that till the decision of this application interim bail may kindly be granted
to the accused;

(c)________that the directions may kindly be issued to the police to get the
accused medically examined immediately;
d) Such other orders be also passed in favour of the applicant/accused as
deemed fit and proper in the facts and circumstances of the case and in the
interest of justice.

AND FOR THIS ACT OF KINDNESS, THE HUMBLE APPLICANT AS IN
DUTY BOUND, SHALL EVER PRAY. 

…………………………… Applicant/Petitioner

______

Through, Advocate

Note:-

This application is filed through the father and next friend of the
applicant/accused, Mr………. _____. It is, therefore, prayed that the
application of the applicant/accused may kindly be allowed and the
applicant/accused may kindly be released on interim bail in the interest of
Justice.

…………………………….

Applicant

—————-

Through, Advocate

IN THE HONBLE DISTRICT AND SESSION COURT AT

…………………………..

Cr MP (M) No:______ of 20….

…………………………………………………………………………..Applicant
………………………………………………………..……………………………….Petiti
oner

Versus

……..……………………………..State
of…………………….……………………… through Public Prosecutor

Affidavit in support of application under Sec 438 of CrPC

I, _______________________________, do hereby solemnly affirm and
declare as under :-

1. That the accompanying application has been prepared under my
instructions.

2. That the contents of paras 1 to ___________________________ of the
accompanying application are correct and true to the best of my
knowledge.

3. That I further solemnly affirm and declare that this affidavit of mine is
true, no part of it is false and nothing material has been concealed therein.

Affirmed at………………………………. this the ____________________.

Deponent